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Hot Tax Practice, Procedure, and Ethics Issues

Stay updated on critical tax and ethics issues, including IRS changes, Supreme Court rulings, and strategies for high-net-worth client representation.

Many practitioners recognize that the IRS and various state taxing authorities view the administrative regulations as mandatory and binding. However, recent court cases, including the Supreme Court's decision in Loper Bright et al., has changed the landscape. Further, with the increase in IRS funding and expected increase in high net worth audits, representing clients that have high net worths has become a more significant and more challenging process. This program includes a discussion of timely tax and ethics issues that the tax practitioner needs to be made aware of. An update on 'hot' IRS practice, procedure and ethics issues, including the impact of the U.S. Supreme Court's decision in Loper Bright; and ethical and practical blunders and mistakes practitioners should avoid.

Learning Objectives

  • You will be able to recognize the requirements of the Administrative Procedures Act according to the Loper-Bright decision and its impact on IRS regulations.
  • You will be able to identify the significance of privilege waiver issues in tax planning, the importance of a good Form 8283 in non-cash charitable contributions, and the IRS's stance on informal refund claims.
  • You will be able to differentiate between the IRS's stance on high net worth audits, passive loss cases, and the two-business issue.
  • You will be able to recognize what a cost segregation study is, what Section 183 is concerned with, what a protective refund claim is, what forms are typically used to file a refund claim, and the penalty for civil fraud according to the IRS.

91 minutes
Course Exam
Certificate of Completion
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Why Lorman?

Over 38 years and 1.4 million customers worth of experience providing continuing education. Our passion is providing you world-class training to help you succeed in business and as a professional.

Agenda

What Do IRS Regulations Mean After Loper Bright?

  • Chevron and the History of Court's Being Bound by IRS Regulations
  • Judicial Deference to the IRS
  • Current State of the Law
  • Hot Issues

High Net Worth Audits

  • What Are the Hot Issues
  • How to Prepare for a High Net Worth Audit
  • Responding to IRS Requests for Information
  • Valuation Issues

Employment Tax and Form 941 Audits

  • Is the ERC the New Hot Issue?
  • Addressing the Affirmative Tax Audit
  • How to Negotiate an Interest Free Investment

Hot Issues

  • The Section 41 Research Credit
  • Ethical Concerns
  • Refund Claim Traps and What the Practitioner Should Be Concerned About
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Why Lorman?

Over 38 years and 1.4 million customers worth of experience providing continuing education. Our passion is providing you world-class training to help you succeed in business and as a professional.

Credits

OnDemand Course

This course was last revised on January 28, 2025.

Call 1-866-352-9540 for further credit information.

  • CPE/NASBA - QAS Self Study 2.5 including Taxes 2.5
     
  • Noggin Guru, Inc. dba Lorman Education Services and BankersHub is registered with the National Association of State Boards of Accountancy (NASBA) as a QAS Self Study sponsor of continuing professional education on the National Registry of CPE Sponsors. State boards of accountancy have final authority on the acceptance of individual courses for CPE credit. Complaints regarding registered sponsors may be submitted to the National Registry of CPE Sponsors through its web site: www.nasbaregistry.org. For more information regarding administrative policies such as complaint and refund, please contact our offices at 866-352-9539. CPE Credit: Maximum Credit Hours: 2.5 each session (based on a 50 minute credit hour). You must attend at least 50 minutes to obtain credit. Field of Study: Taxes for 2.5 hours. Prerequisite: . Level of Knowledge: Intermediate. Teaching Method: Seminar/Lecture. Advance Preparation: None. Delivery Method: QAS Self Study. Please refer to the information in this advertisement for outline, course content and objectives. Upon completion of this course, you will receive a certificate of attendance. Final approval of a course for CPE credit belongs with each state's regulatory board.
     

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This program does NOT qualify, nor meet the National Standard for NASBA accreditation.

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Why Lorman?

Over 38 years and 1.4 million customers worth of experience providing continuing education. Our passion is providing you world-class training to help you succeed in business and as a professional.

Faculty

Michael G. Goller

Michael G. Goller

Reinhart Boerner Van Deuren S.C.

  • Shareholder in Reinhart’s Corporate and Tax Department and served as the Tax Department Chair for over 10 years
  • Over 30 years of experience with practice focusing on tax controversy, tax litigation, and tax planning
  • Represents clients involved in complex disputes with the IRS, the U.S. Department of Justice and various other authorities and has an impressive track record of favorable settlements Writer and speaker on a variety of tax controversy, litigation, and planning topics
  • Faculty member at the University of Wisconsin-Milwaukee’s Lubar School of Business and teaches Tax Practice and Procedure in the Graduate Tax Program
  • Named ‘Lawyer of the Year,’ Best Lawyers’ 2014 Milwaukee Litigation & Controversy Law-Tax, Best Lawyers in America, and selected for inclusion in Wisconsin Super Lawyers
  • J.D. Degree, cum laude, Marquette University Law School; B.S. Degree in accounting, Marquette University
  • Can be contacted at [email protected] or 414-298-8336
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Why Lorman?

Over 38 years and 1.4 million customers worth of experience providing continuing education. Our passion is providing you world-class training to help you succeed in business and as a professional.

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All of your training, right here at Lorman.

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Product ID: 411801
Published 2025
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